Anti-Bribery & Corruption Policy

1. Policy Statement

MyCustomsInfo® is committed to conducting business with the highest standards of ethics, integrity, and transparency. We have a zero-tolerance policy toward bribery and corruption in all forms. This policy applies to all employees, directors, officers, contractors, consultants, agents, and business partners acting on behalf of MyCustomsInfo®.

We are committed to complying with all applicable anti-bribery and anti-corruption laws, including but not limited to the UK Bribery Act 2010, the US Foreign Corrupt Practices Act (FCPA), and other relevant national and international legislation.

2. Scope and Application

This policy applies to:

• All MyCustomsInfo® entities, subsidiaries, and controlled affiliates worldwide
• All employees, regardless of position or location
• All directors, officers, and board members
• All contractors, consultants, and temporary workers
• All agents, intermediaries, and representatives acting on our behalf
• All business partners, including suppliers, distributors, and joint venture partners

This policy applies to all business activities, both in the UK and internationally, and in both the public and private sectors.

3. Definitions

4. Prohibited Conduct

The following activities are strictly prohibited:

5. Gifts, Hospitality, and Entertainment

While modest gifts and reasonable hospitality are normal business courtesies, they must never be used to influence decision-making or create a sense of obligation.

5.1 Acceptable Practices

The following are generally acceptable, provided they meet the criteria below:

• Modest gifts (e.g., branded items, seasonal gifts) of nominal value
• Reasonable business meals and entertainment
• Attendance at industry conferences and events
• Promotional items and marketing materials

5.2 Criteria for Acceptable Gifts and Hospitality

Gifts and hospitality must:

• Be modest and proportionate (generally not exceeding £100 / $150 in value)
• Be transparent and properly documented
• Comply with the recipient's organization's policies
• Be given openly, not secretly
• Be infrequent and not form a pattern
• Not be given in cash or cash equivalents
• Not be intended to influence a business decision
• Not create a sense of obligation
• Be consistent with local laws and customs

5.3 Prior Approval Requirements

Prior written approval from your line manager is required for:

• Any gift or hospitality exceeding £100 / $150 in value
• Any gift or hospitality involving a public official (regardless of value)
• Travel or accommodation expenses
• Gifts or hospitality in connection with a tender or contract negotiation
• Any gift or hospitality that could be perceived as inappropriate

5.4 Gifts and Hospitality to Public Officials

Special care must be taken when dealing with public officials:

• All gifts and hospitality to public officials must be pre-approved
• Only modest promotional items may be given
• Hospitality must be reasonable and business-related
• Cash or cash equivalents are strictly prohibited
• All interactions must be properly documented

6. Charitable Donations and Sponsorships

6.1 Charitable Donations

We support legitimate charitable organizations, but donations must:

• Be made to legitimate, recognized charitable organizations
• Be properly documented and approved
• Not be used as a disguised bribe or to gain improper advantage
• Comply with applicable tax and regulatory requirements
• Be transparent and publicly disclosed where appropriate

6.2 Sponsorships

Sponsorships of events, organizations, or individuals must:

• Have a legitimate business purpose
• Be properly documented in a written agreement
• Be proportionate to the expected business benefit
• Not be used to improperly influence business decisions
• Be approved by senior management

7. Third-Party Relationships

We may be held liable for bribery or corruption committed by third parties acting on our behalf. Therefore, we must exercise due diligence when selecting and managing third-party relationships.

7.1 Due Diligence

Before engaging agents, consultants, intermediaries, or business partners, we must:

• Conduct risk-based due diligence on their reputation, qualifications, and integrity
• Verify their ownership structure and management
• Check for any connections to public officials or high-risk parties
• Review their anti-bribery and compliance policies
• Assess the reasonableness of their proposed fees
• Understand their role and services to be provided

7.2 Contractual Requirements

Contracts with third parties must include:

• Anti-bribery and anti-corruption clauses
• Warranties that they will comply with applicable laws
• Audit and inspection rights
• Termination rights for non-compliance
• Clear descriptions of services and fee structures

7.3 Ongoing Monitoring

We monitor third-party relationships through:

• Regular reviews of services provided and fees paid
• Periodic re-screening and due diligence
• Training and communication of our expectations
• Investigation of any red flags or concerns
• Documented approval processes for payments

8. Political Contributions

MyCustomsInfo® does not make political contributions using company funds or resources. Employees are free to make personal political contributions in their individual capacity, but must ensure that such activities:

• Are made using personal funds, not company funds
• Do not create a conflict of interest
• Are not made in the company's name
• Comply with applicable campaign finance laws
• Are not intended to influence business decisions

9. Record-Keeping and Financial Controls

9.1 Accurate Records

All financial transactions must be:

• Accurately and completely recorded in our books and records
• Supported by appropriate documentation
• Properly described and classified
• Approved in accordance with our authorization policies
• Subject to regular audit and review

9.2 Prohibited Practices

The following are strictly prohibited:

• Maintaining off-book accounts or undisclosed funds
• Making false or misleading entries in books or records
• Creating fictitious or incomplete documentation
• Making payments without proper approval or documentation
• Destroying or altering records to conceal improper activities

10. Reporting and Whistleblowing

10.1 Duty to Report

All employees have a duty to report any suspected or actual bribery or corruption. You must report:

• Any requests for bribes or improper payments
• Any offers or promises of bribes
• Any suspicious payments or financial irregularities
• Any concerns about third-party conduct
• Any pressure to engage in improper conduct

10.2 Reporting Channels

Reports can be made through any of the following channels:

10.3 Protection Against Retaliation

We prohibit retaliation against anyone who reports concerns in good faith. Protected activities include:

• Reporting suspected violations
• Participating in investigations
• Refusing to engage in improper conduct
• Cooperating with law enforcement or regulatory authorities

Any retaliation will be treated as a serious violation and may result in disciplinary action, including termination.

11. Investigation and Disciplinary Action

11.1 Investigation Process

All reports of suspected bribery or corruption will be:

• Taken seriously and investigated promptly
• Handled confidentially to the extent possible
• Conducted by qualified, independent investigators
• Documented thoroughly
• Reported to senior management and the Board as appropriate

11.2 Disciplinary Action

Violations of this policy may result in:

• Disciplinary action, up to and including termination of employment
• Termination of business relationships with third parties
• Legal action and criminal prosecution
• Recovery of losses and damages
• Reporting to law enforcement and regulatory authorities

12. Training and Communication

We provide regular training and communication on anti-bribery and anti-corruption:

• Mandatory training for all employees upon joining
• Regular refresher training (at least annually)
• Specialized training for high-risk roles and functions
• Communication of policy updates and relevant case studies
• Resources and guidance materials available on our intranet
• Opportunities to ask questions and seek guidance

13. Governance and Oversight

Responsibility for this policy is assigned as follows:

• Board of Directors: Overall oversight and approval of policy
• Chief Executive Officer: Ultimate accountability for implementation
• Chief Compliance Officer: Policy administration, monitoring, and reporting
• Senior Management: Implementation within their areas of responsibility
• All Employees: Compliance with policy requirements

14. Policy Review and Updates

This policy is reviewed at least annually and updated as necessary to reflect:

• Changes in applicable laws and regulations
• Lessons learned from incidents or near-misses
• Evolving business risks and activities
• Best practices and industry standards
• Feedback from employees and stakeholders

15. Contact Information

For questions about this policy or to report a concern: